Henderson v. Morgan

Defendant was indicted on a charge of first-degree murder. Defendant had spent several years in a state school for those with intellectual disabilities. After being released from the state school, the Defendant killed his employer following an argument between the two. The Defendant’s counsel attempted to negotiate a plea deal for manslaughter, but the prosecution would only agree to reduce the charge to second-degree murder. The Defendant subsequently pled guilty to the second-degree murder charge. After sentencing, the Defendant appealed. He argued that his plea was involuntary because he was not advised that an intent to cause death was an element of second-degree murder and had he known that, he would not have pled guilty. The Court held that the defendant’s plea was involuntary because he did not receive adequate notice of the offense to which he pled guilty. The Court rooted its decision in the fact that at the plea colloquy, there was no discussion of the elements of the charged offense, no indication that the Defendant had been advised on the nature of the charged offense, and that there was no reference to the requirement of intent to cause the death of the victim. Further, there was nothing in the record that could serve as a substitute for a voluntary admission from the Defendant. The Defendant’s counsel did not stipulate that the Defendant had the requisite intent, they did not explain to the Defendant that his plea would be an admission of that fact, and the Defendant made no statement implying that he had the intent to commit second-degree murder.

“[A] plea cannot support a judgment of guilt unless it was voluntary in a constitutional sense. And clearly the plea could not be voluntary in the sense that it constituted an intelligent admission that he committed the offense unless the defendant received ‘real notice of the true nature of the charge against him, the first and most universally recognized requirement of due process.'” p.644-645